The information on this website (Site) is published by OTT. Any contents or information (the
"Information") contained on this Site are provided
as a general source of information on ly and should not be considered as advice on any investments
or services of OTT, and OTT will not be held
liable for inaccuracies in the information presented.
If you wish to access and use this Site, you must accept and agree to be bound by and comply with
the terms below. Before using this Site,
please carefully read the following terms:

IMPORTANT NOTICE: THE FOLLOWING STATEMENT GOVERNS USE OF THIS SITE. BY ACCESSING THIS SITE, YOU
ACKNOWLEDGE AND
AGREE WITH THE FOLLOWING TERMS. IF YOU DO NOT AGREE TO THESE TERMS, PLEASE EXIT OR DO NOT ACCESS
THIS SITE.

Use of this Site

Access to this Site is subject to applicable procedures of OTT, which may be developed or updated
from time to time. OTT will make its best
efforts to keep this Site operational. However, OTT cannot guarantee that the Site will always be
accessible, and may in its sole discretion,
modify, suspend or terminate the access or services provided to you through this Site without
notice.
The contents of this Site are provided for informational purpose, and are not intended to provide
specific individual advice including, without
limitation, investment, financial, legal, accounting or tax. Please consult with your own
professional advisor on your particular circumstances.

Site Content

All content or any price information on the Site is presented only as of the date posted and may be
superseded by subsequent market events or
for other reasons. The contents or information provided on the Site may be changed, modified or
updated from time to time without prior
notice. You agree to review the Site regularly and accept those modifications if you continue to use
the Site.
Reasonable effort has been made to ensure that the information and material contained in this Site
is accurate and up-to-date at the time of
posting. However, OTT cannot guarantee the accuracy, completeness or authenticity of any site
content or site functionality, and accepts no
responsibility for any loss arising from any use of or reliance on the information contained herein
on the Site.

Third Party Websites or Links

Links to other parities' web sites are intended for convenience only. OTT does not review, endorse,
approve or control the content of those sites
or their products and services. Similarly, OTT does not endorse sites which refer to our site.
Linking to any other site is at your sole risk and OTT
will not be responsible or liable for any damages in connection with linking or any consequences
associated with contents of those sites.

No Endorsements

The inclusion of any Site information, acknowledgments or identification of persons and entities
shall not, in any manner, be construed as an
endorsement for the product, person or entity by OTT. No endorsement or approval of any third
parties or their advice, opinions, information,
products or services is expressed or implied by any Information on this Site.

Security and Confidentiality

The Internet is not a secure medium to ensure privacy or security, and use of the Internet or a
website (including information transmitted to the
website) may be subject to access by, or disclosure to, other persons. As such, complete security
and confidentiality over the Internet is not
possible. As with other communication medium (e.g. cell phones, mail), any unprotected E-mail
communication over the Internet is not
confidential, subject to possible interception, alteration or loss. OTT shall not be responsible or
liable for any harm that you or any other person
may suffer in connection with any such breach of confidentiality or security.
Personal, confidential and/or proprietary information with respect to OTT's clients or business can
only be accessed by OTT's employees,
account representatives, and officers, and should be kept confidential and not shared with any
unauthorized persons or parties.

Privacy

Information provided to OTT through this Site or other means is used for intended business purposes
only in order to serve you as an existing
or prospective client. Personal information that you disclose while visiting the Site will be
respected by OTT, and policies governing the
protection of privacy on the Site are observed and developed. OTT takes any reasonable steps to
prevent unauthorized access to this Site.
Related technology or technical and navigational information may be used to improve web
functionality for a better service.

Copyright and Trademarks

This Site is proprietary to OTT, and the contents of the Site are protected by applicable copyright
laws. All texts, illustrations, graphics and
images displayed on the Site are and shall remain at all times the property of the OTT. Without
express prior written permission from OTT, no
one is granted to copy, distribute, modify, post, or produce any text, graphics, video audio,
software code or user interface design or logos. Any
unauthorized use or exploitation of such marks and names of OTT or retransmission, or other copying
or modification of trademarks and/or the
contents of this Site is strictly prohibited.
Most of names, titles, phrases, logos, icons, words, graphics or designs or other content in this
Site may constitute trademarks or trade names,
registered or not, property of OTT, its affiliated companies or subsidiaries and represent only part
of their intellectual property. The display of
trademarks and trade names in this Site does not imply that a license of any kind has been granted,
and you are not permitted to use these
marks or names without express consent from OTT.

Governing Laws

The laws of the Province of Ontario and the applicable federal laws of Canada shall govern as to the
interpretation, validity, and any use of the
Site. You hereby agree that any litigation arising out of or in connection with the use of this Site
shall be exclusively in the province of Ontario
courts of Canada.

Disclaimer of Liability

Use of the Site shall be on an "as is" basis entirely at your own risk. Neither OTT, nor any of its
affiliates, nor any officer, director, or employee,
nor those associated with the creation of the Site or its contents, shall be liable or responsible
in any way for any harm, loss or damage that may
arise in any connection with your use of this Site or reliance upon the Site or its contents
whatsoever, including without limitation any direct,
indirect, special, third party, incidental, economic, or consequential damages, exemplary or
punitive or any unauthorized use or reproduction of
the Information on the Site, even if OTT has been advised of the possibility of such damages.

Other

All products and services of OTT and its any affiliates are subject to the terms and conditions as
specified in the applicable account applications
or services agreements, and a client’s account or business relationship can only be established
through such documents signed with OTT, which
will govern the use of OTT’s products or services.
All obligations of OTT with respect to products and services on this Site are subject to acceptance
or approvals of the applications by OTT.
In case of discrepancies between the English and other language versions of the Terms above and
content of this Site, the English version shall
prevail.

If you have any questions?

It is OTT’s policy to respect confidentiality and privacy of individuals who open an account or have
a business relationship with OTT. Under the
applicable law, OTT has an obligation to collect information from its clients and verify their
identity to meet regulatory requirements. This
Privacy Policy or Statement sets out the ways OTT managing client information upon receipt of
personal information submitted.
In accordance with current federal and applicable provincial legislation in Canada, including the
federal privacy law “the Personal Information
Privacy and Electronic Documents Act (PIPEDA)”, OTT has adopted privacy practices to protect
personal information as part of its overall service
commitment to its clients, and makes reasonable efforts to keep personal information secure and
confidential. Each employee of OTT is
required to handle clients’ personal information properly and perform duties in compliance with this
Privacy Policy.

Principles of PIPEDA

Principle 1 – Accountability

Each employee of an organization is responsible for personal information under his or her control
and designated individual(s) shall be
accountable for compliance with its Privacy Policy.

Principle 2 – Identifying Purposes

The purposes for which personal information is collected shall be identified before or at the time
the information is collected.

Principle 3 – Consent

The prior knowledge and permission of the individual are required for the collection, use or
disclosure of personal information, except for legal
or security reasons.

Principle 4 – Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes
identified. Personal information shall be
collected by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention

Personal information will not be used, disclosed or retained for purposes other than those stated at
the time of collection, except with the
permission or consent of the individual, or as permitted or required by law.

Principle 6 – Accuracy

Personal information shall be as accurate, complete and current as is necessary for the identified
purposes for which it is to be used.

Principle 7 – Safeguarding Information

Personal information will be protected by safeguards appropriate to the sensitivity of the
information.

Principle 8 – Openness

The policies and procedures of an organization relating to the management of personal information
will be made readily available to its clients
and employees for specific information.

Principle 9 – Individual Access

Upon request, an individual will be informed of the existence, use and disclosure of his or her
personal information and shall be given access to
it. An individual will be able to challenge the accuracy and completeness of the information and
have it amended as appropriate.

Principle 10 – Handling Client Complaints and Suggestions

Individuals can address any complaint regarding compliance with the above principles to the Privacy
Officer of an organization.

Privacy Practices of OTT

OTT recognizes an individual’s right to privacy and adheres to the above ten principles of PIPEDA
when using personal information for legitimate
business purposes. The above privacy regulations pertain to all employees or representatives of OTT.
Each employee of OTT is required to be
responsible for client personal information under his or her control and designated officers are
accountable for compliance with this Policy.
Personal information refers to information that can identify an individual, including age, marital
status, home address and telephone number,
personal email address, employment history, social insurance number, bank account information or
credit history etc. Such information may be
provided to us on an account application or a business contract signed, or by a phone call,
correspondence in mail or email to us, or by use of
our website.

Why Your Personal Information Is Required

OTT is required by law to obtain and collect certain personal information about you as a client in
order for us to set up and maintain an account
or provide services for you. As stated below, such information will allow OTT to carry out its
obligations under law and policies regarding client
identification and verification, and help establish a relationship with you and provide the best
possible service to meet your needs.

* To understand and establish your identity as a client;
* To create a client record or file as required at OTT;
* To understand your needs and assess your eligibility for our services and products;
* To provide you with the services you have agreed to obtain from OTT;
* To maintain business relations and protect you and us from error or any fraud; and
* To comply with all applicable law, regulations and compliance requirements.

Obtaining Your Consent

You consent is obtained before or at the time opening an account or establishing a relationship with
OTT. At such times, you will be required to
provide certain personal information in order for us to establish the account or provide you
services. The information may be collected via an
OTT application form or agreement, in which case you will formally indicate your consent for OTT to
collect and use your personal information
when you sign the application or agreement. You may wish to withdraw your consent; however, without
required information, OTT may not be
able to maintain your account or provide you services requested.

Purposes of Using Your Personal Information

After your personal information is provided to OTT’s employees or representatives, OTT may use it
for the following purposes:

* To identify you as a client and create a Client Record or client information file for you;
* To establish and administer your account, and execute your transactions or services requested;
* To maintain, store, record and determine your account, transactions or services related
records;
* To ensure our records about you are accurate, and verify information obtained when necessary;
* To provide you with your account, transactions or services related confirmations or statements,
receipts or other information that may be
requested or needed to meet your needs;
* To provide you with quality client service and support on your account, transactions or
services;
* To maintain our business relationship with you and protect the interests of you and OTT; and
* To meet all applicable legal, regulatory and compliance requirements of OTT, such as the Proceeds
of Crime (Money Laundering) and Terrorist
Financing Act.

When communicating with you for the purposes above, you consent to receiving your account,
transactions or services related communications
from us in any form, including mail, email, or phone call, or Internet.

How Personal Information Is Collected and Recorded

OTT collects personal information from you as a client in a number of ways as stated below. These
ways apply to all methods of collecting
personal information including hard copy, electronic and verbal means, and the personal information
provided by you will only be used for the
purposes indicated in the section above.

* Directly from you, when you provide information and sign on OTT’s account application or agreement
or transaction documents completed
and submitted to OTT for services or products you requested.
* Your voluntary disclosure of personal information directly to OTT by phone, mail, email, or our
website, and such client account or service
related information will be recorded and kept properly.
* By contacting OTT staff or through those you authorized in writing to conduct business on your
behalf.

OTT protects your personal information by using appropriate storage, which may be kept in electronic
or paper format, and is gathered in a
“Client Record”. Such record or client file may include information about your name, date of birth,
address, phone number, identification,
occupation etc. Depending on the type of business or service duties required, OTT may need to keep
additional information about your account,
transactions or when identified as a necessity during the business process, or as required by
applicable law or compliance policy.
During the process of providing services to you, OTT employees are required to obtain accurate,
complete and current personal information
from you, and keep it updated as is necessary for the identified purposes related to your account,
transactions, or services. Such information is
required to be provided and updated timely in order for us to provide you with better services and
meet our regulatory requirements.

Limiting Use, Disclosure and Retention of Personal Information

Any personal information collected from you will only be used for the purposes identified at the
time of collecting and will be retained for as
long as is necessary to serve your account, provide services, or retain it for a period as required
by applicable law or requirements. If certain
information requested is not provided, OTT may not be able to assess your application or needs.
In the course of business activities, all employees of OTT and authorized representatives or service
providers are required to protect the
confidentiality of client personal information for limited use and stated purposes only. Access to
your personal information is restricted to those
authorized staff and representatives or service providers who need it to do their jobs. Under no
circumstances client personal information will
be given or sold to other companies for their own use.
OTT may disclose your personal information to a related third party, business partner or government
agency under certain circumstances
below. This is done only to meet your service requirements or as may be required by any relevant law
or government agencies.

* If a disclosure is connected to the purposes indicated by using service providers authorized, in
which case, OTT signs an agreement with it to
ensure appropriate controls and protections are in place;
* You have authorized us to do so for services needed by using financial institutions nominated by
you;
* It is required by law, government agencies, or legal requests related to your account activities.

Protecting and Safeguarding Your Personal Information

OTT is committed to protecting your personal information in a manner consistent with our privacy
practices. In order to ensure client personal
information is protected, OTT keeps client information securely in its offices, and requires all its
employees to adhere to related policies and
procedures during daily work when handling client information, and takes appropriate security
measures to safeguard your personal
information. The security measures used include the following:

* Physical access security, restricted access to our offices;
* Passwords set up on our systems;
* Limited access to client records for those staff who need to know for their work;
* File encryption put in place to avoid unauthorized access, modification, or use;
* Requiring authorized third party service providers or business partners to take appropriate
measures to secure our client information or
remedy it if a breach is occurred;
* Disposing or destroying personal information as required by following procedures to use proper
means or safeguards to prevent those
unauthorized from gaining access to the information during the process.

Right to Access Your Personal Information

You have the rights to know and ask questions about your personal information after your personal
information has been provided to OTT for
your account set up, transactions or services signed. The right may include the following:

* Whether we hold any personal information about you;
* How we collect, use or disclose your personal information;
* Whether and how you can see or access that information;
* Accuracy or completeness of your personal information;
* Other questions or issues you may have about your personal information.

You can contact us by phone, fax, mail or email by using the contact information listed
below. When requesting access to your information,
normally a full access to your information is provided. However, there may be some legal or
administrative limitations for certain cases.
You may also request the specific information about our policies and procedures relating to the
management of your personal information by
reviewing this Policy or contacting us by using the information provided below.

Changes to this Privacy Policy

Our Privacy Policy may change from time to time to reflect changes in our policies, applicable
rules, regulations, or related compliance
requirements. It is important for you to review this Privacy Statement by visiting our website
regularly, as such changes may be made without
prior notice.

Resolving Your Questions and Concerns

OTT employees are required to record and maintain the accuracy of your personal information on your
file and ensure that it is accurate,
complete and up-to-date. However, from time to time, there may be an error occurred. If you find any
inaccurate information on your account
or transactions, or your personal information has changed, please notify us immediately. We will
correct or update it timely.
In addition, if you have any questions, concerns or a complaint about your personal information,
please contact us directly by using one of the
methods below. Upon receipt of your request or complaint, we will contact you as soon as possible to
ensure that the necessary corrections or
changes are made timely, and will act diligently to address your concerns or resolve problems
appropriately.